Cramblitt v. Bisignano
- David Schultz
- 0:25-cv-00746
- U.S. District Court · District of Minnesota
- 5
In Charles A. C. v. Bisignano, Judge Blackwell upheld the Social Security Administration's denial of disability benefits, finding the administrative judge's decision was supported by substantial evidence.
Individuals who have been denied Social Security disability benefits and are challenging the ALJ's residual functional capacity findings, particularly where the ALJ's work-limitation language differs from terminology used by agency-appointed psychologists.
What happened
In Charles A. C. v. Frank Bisignano, Commissioner of Social Security (No. 25-746), the plaintiff sought federal court review of the Social Security Administration's decision to deny his application for disability benefits. The central dispute was whether the administrative law judge (ALJ) who decided the case made a reversible error by limiting the plaintiff to 'superficial' interactions with others at work, rather than 'brief and superficial' interactions as two agency psychologists had recommended. The plaintiff argued the ALJ failed to explain this difference and that a Magistrate Judge's report improperly filled in the ALJ's reasoning.
The Magistrate Judge recommended affirming the agency's decision, and the plaintiff objected. The court reviewed the objected-to portions fresh (called 'de novo' review) and the rest of the report only for obvious errors. The court focused on whether there was a logical connection between the evidence in the record and the ALJ's conclusions, and whether the omission of the word 'brief' from the plaintiff's work limitations created a meaningful conflict with the psychologists' opinions.
Judge Jerry W. Blackwell overruled the plaintiff's objection and accepted the Magistrate Judge's report. The court found that the ALJ directly explained why he did not use the word 'brief' — because the term lacks a standard vocational definition — and instead used specific, vocationally defined examples of superficial interactions. The court concluded that these examples, such as taking instructions and relaying information, are consistent with brief interactions, that the agency psychologists never defined 'brief' in a way clearly at odds with the ALJ's findings, and that the record as a whole supported the ALJ's decision. The plaintiff's request to reverse or send the case back to the agency was denied, and the Commissioner's decision was affirmed.
The detailed version
- Cramblitt v. Bisignano · No. 0:25-cv-00746
- David Schultz
- Oct. 7, 2025
Background
The plaintiff, Charles A. C., applied for Social Security disability benefits and was denied by an administrative law judge (ALJ) — the agency official who hears disability cases. He then sought judicial review in federal district court, as is his right under the Social Security Act. The case was referred to United States Magistrate Judge David T. Schultz, who on August 6, 2025, issued a Report and Recommendation (R&R) recommending that the plaintiff's request to reverse or remand (send back to the agency) be denied, and that the Commissioner's decision to deny benefits be affirmed. The plaintiff timely filed objections to the R&R.
Standard of Review
Under 28 U.S.C. § 636(b)(1) and District of Minnesota Local Rule 72.2(b)(3), a district court reviews de novo (fresh, without deference to the magistrate) any portion of an R&R to which a party objects. Portions not objected to are reviewed only for clear error. Separately, an ALJ's disability determination is reviewed to assess whether it is supported by substantial evidence in the record as a whole and whether it follows applicable legal standards. See Kraus v. Saul, 988 F.3d 1019, 1024 (8th Cir. 2021). The controlling standard does not require the ALJ to specifically address every possible limitation or piece of conflicting evidence, but does require a 'logical bridge' between the evidence and the ALJ's conclusions. See Austin v. Kijakazi, 52 F.4th 723, 729 (8th Cir. 2022).
The Dispute: 'Superficial' vs. 'Brief and Superficial' Interactions
The sole objection raised by the plaintiff was that the ALJ failed to adequately explain why the plaintiff's residual functional capacity (RFC) — the ALJ's formal assessment of what work a claimant can still do — limited him to 'superficial' interactions with others, rather than 'brief and superficial' interactions as two agency psychologists had opined. The plaintiff argued the R&R improperly supplied a rationale the ALJ himself never gave.
The court rejected this argument for several reasons:
1. The ALJ directly addressed the omission of 'brief.' The ALJ explicitly stated that he declined to use the term 'brief' because it is not vocationally defined, and instead chose 'more specific, vocationally defined, and policy compliant language.' (A.R. 4024–25.) This was not a case of the ALJ simply forgetting or ignoring the psychologists' opinions.
2. The ALJ provided specific examples of superficial interactions. Rather than using only the general term 'superficial contact,' the ALJ specified that the plaintiff's interactions would be limited to 'taking instructions, relaying information, and transferring material.' (A.R. 4017, 4025.) The court found these examples are consistent with brief interactions, citing Tria V. H. v. Colvin, Civ. No. 23-2979, 2025 WL 66505 (D. Minn. Jan. 10, 2025).
3. The agency psychologists did not define 'brief' in a way clearly inconsistent with the ALJ's findings. The court cited Jennifer L. v. Comm'r of Soc. Security, Civ. No. 23-1822 (KMM/TNL), 2024 WL 4003021 (D. Minn. Aug. 30, 2024), for the proposition that when agency psychologists do not explain their terminology in a way that is clearly at odds with the ALJ's findings, no reversible inconsistency exists.
4. The record supported not expressly limiting interaction duration. The ALJ assessed evidence of the plaintiff's mental limitations and ability to interact with others, including evidence of longer-duration interactions and events post-dating the agency psychologists' opinions. (A.R. 4015–16, 4022–23.) The court found nothing in the record indicating the ALJ's findings lacked evidentiary support or that he disregarded the psychologists' views.
Ruling
Judge Blackwell overruled the plaintiff's objection, accepted the Magistrate Judge's R&R, denied the plaintiff's request to reverse or remand, granted the Commissioner's request to affirm, and affirmed the Commissioner's decision. Judgment was ordered to be entered accordingly.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.